The nature of the purpose requirement of an impermissible tax avoidance arrangement

The nature of an inquiry into the purpose requirement of an impermissible tax avoidance arrangement can either be objective or subjective. In essence, an objective inquiry has regard to the ‘effect’ of an arrangement, as opposed to a subjective inquiry which has regard to the taxpayer’s ipse dixit. Although the purpose requirement under section 103(1) was a subjective inquiry, case law decided under section 103(1) revealed that a taxpayer’s ipse dixit was weighed and tested against the surrounding facts and circumstances. This introduced an element of objectivity into the interpretation of the purpose requirement. Tax scholars have various opinions regarding the nature of the test in the new purpose requirement in sections 80A and 80G. It seems that the amendments to the purpose requirement merely confirm the approach which was applied by our courts under the repealed section 103(1). The nature of the purpose requirement, therefore, in essence, seems to have stayed unaltered

The factor structure, metrical properties, and convergent validity of the third edition (1999) of the Locus of Control Inventory.

The principal objective of the study was to examine the factor structure and metrical properties of the third edition (1999) of the Locus of Control Inventory (LCI). A corollary of the study was to examine the convergent validity of the instrument. After a thorough revision and extension of the scale to 88 items it was applied to a sample of 2091 first-year university students. Particular attention was paid to the shortcomings revealed in a study by de Bruin (2004). An iterative principal factor analysis of the scale was done. The three-factor-structure previously found was substantiated by the analysis. The obtained factors were interpreted as Autonomy, External Control and Internal Control. Highly acceptable reliabilities were obtained. As far as validity is concerned it was found that Internal Control and Autonomy are strongly related to Psychological Wellness and External Control negatively to Stress Management. The implications of the findings are discussed

An integrated strategic management model to navigate the establishment of transport authorities.

This research covered the strategic intent for the transport industry and an overview of Transport Authorities in the municipal sphere of government. Representative sets of strategic management and change navigation models, as well as Swanepoel’s (2001) model being used in the management of change in the public sector, were reviewed. An integrated strategic management model, which incorporates principles from strategic management and change navigation, is proposed for navigating the establishment of Transport Authorities. This model consists of six phases, namely: Awareness and Mobilisation; Strategic Synthesis and Choice; Strategy Crafting; Strategy Implementation; Performance Monitoring and Review; and Stabilisation. Recommendations follow regarding the validation of the model in a pilot project

Monitoring the Effect of Micro-oxygenation before Malolactic Fermentation on South African Pinotage Red Wine with Different Colour and Phenolic Analyses

The use of micro-oxygenation and its effect on the quality of the red wine varietal, Pinotage, is largelyunknown. The influence of adding different oxygen dosages before malolactic fermentation on thephenolic composition and colour stabilisation of wine made from Pinotage was studied, and thesuitability of certain spectrophotometric and RP-HPLC analyses to determine these changes wereassessed in tanks of commercial lengths. Total oxygen dosages of 0 mg/L, 16 mg/L and 32 mg/L wereapplied, after which the wines underwent malolactic fermentation and maturation in the same tanks fortwo additional months. Decreases in anthocyanin concentration showed a strong inversely proportionalcorrelation with increasing polymeric pigment concentration. This suggests that the addition ofoxygen contributed to the early stabilisation of wine colour in Pinotage red wine. Overall, tanninconcentrations were not significantly influenced by the oxygen treatments, although lower levels wereobserved in wines treated with oxygen. An important finding of the study was that there appeared to belittle difference in the colour and phenolic composition of the wines between the 16 mg/L and 32 mg/Loxygen treatments. Good correlations were found between certain spectrophotometric techniques andthe RP-HPLC analysis used to study changes induced by micro-oxygenation (total anthocyanins, totalphenols). The colour and phenolic composition of Pinotage wine can be influenced before malolacticfermentation by micro-oxygenation. Some spectrophotometric phenolic analyses showed the sametendencies as observed with RP-HPLC (anthocyanins, monomeric flavan-3-ols, tannins), indicating theirsuitability to follow phenolic and colour changes induced by micro-oxygenation in Pinotage red wine

Integrated risk management : a mechanism to minimise risks for local government : a critical perspective

Thesis (PhD (School of Public Management and Planning ))—University of Stellenbosch, 2006.The absence of an integrated risk management programme in local government in South Africa creates the danger that these risks are not identified, which could be catastrophic, and opportunities to minimise losses are not utilised. A further problem is that common risk-management terminology is lacking and management are dependent on diverse legislation as a guide to developing and implementing risk management. In order to achieve the strategic and operational objectives of local government in an effective and efficient manner, a pro-active identification and evaluation of potential risks should be established to minimise their impact. Officials on every level need to be informed about processes and techniques for managing risks and recalibrating activities to enable management to operate more effectively in risk-filled environments. Problems were identified that prevent management from providing reasonable assurance to stakeholders that the most significant risks are being addressed. These problems are as follows: the lack of applying risk management in an integrated manner; the enforcement of integrated risk management due to the lack of relevant legislation; a lack of training in risk management, ethics and risk response plans; a lack of practical techniques to assist officials in taking remedial action to prevent recurrence of risks; the absence of a risksensitive organisational culture; and a lack of commitment and leadership from politicians and management. Relevant legislation on integrated risk management should assist in embedding a culture where everyone in local government is obliged to adhere thereto and to conduct their dayto- day activities accordingly. A mission and vision statement needs to be developed and implemented with the consent of all stakeholders. Integrated risk-management processes, which are generally lacking or incomplete in local government, should be aligned with generic public management functions. An integrated risk-management programme can be enhanced by establishing a risk organisational structure within local government. The establishment of a risk management department and risk committee is essential to the enhancement of corporate governance and the management of risks that might have a negative impact on local government. Internal and external controls should be evaluated regularly to facilitate the riskmanagement programme. An Integrated Risk Monitoring Technique is proposed as a technique to assist stakeholders in identifying root causes of risks and the management thereof. A model of integrated risk management was designed to assist academics and practitioners to get a holistic perspective on integrated risk management and to assist in the management of risks

Attendee satisfaction in festival activity: Innibos National Arts Festival

Despite the growth in festival tourism in South Africa and the paucity and infrequent nature of festival research, very little research exists on addressing what classifies a festival as successful. Well organized, promoted and managed events have been linked to attendee satisfaction, resulting in a successful event. Similarly, there is a positive connection between customer satisfaction, loyalty and retention which underlines the importance for festivals to be successful and sustainable. This study employs an on-site survey of 500 visitors attending the Innibos National Arts Festival in Mbombela, South Africa. Eight constructs were investigated based on the SERVQUAL and Grönroos model to determine the overall satisfaction of the attendees. The statistical analysis was performed using the marginal distributions of variable and construct analysis based on the post data. This study aimed at determining the overall satisfaction levels of the between attendee’s at the festival

Direct anterior approach in total hip arthroplasty: a narrative review

Objective: Worldwide, a growing number of Total Hip Arthroplasty (THA) procedures are being performed each year. However, despite this significant global demand, the ideal surgical approach remains controversial. Globally there has been a significant increase in the use of direct anterior approach THA. Therefore, the objective of this paper was to synthesise the vast body of new, evolving information into one non-biased narrative review, to provide an overarching review of various aspects of this approach, including controversial issues such as, benefits, functional outcomes, complications, costs, and surgical technique. Data source: The following keywords were entered into various scientific databases including, Mbase, Google scholar and PubMed. Only articles published in journals between 2017 and 2021 were extracted and included in this review. We found 148 articles published during this period and we used the 82 most relevant articles to collate this narrative review. Data selection/ extraction: Three fellowship trained arthroplasty orthopaedic surgeons, (JRTP, LM and JC) went through all the papers and selected the 82 most relevant papers for inclusion in this review. Conclusion: There has been significant interest and renewed vaguer in publication rates by authors worldwide evaluating the use of the DAA in THA. Most recent studies show that there is increasing evidence that the DAA is a safe, reliable, and reproducible surgical approach to THA. Direct anterior approach provides, in the most part, superior early short term functional outcomes in comparison with other THA approaches. It has however also been shown that a steep learning curve exists when using this approach. While complication rates are similar to those seen in other approaches, the types of complications however remain slightly different with an increase incidence of intraoperative peri-prosthetic femoral fractures, wound complications and femoral stem aseptic loosening being significantly greater in the direct anterior approach

The role of tourist guides in interpretation: a survey of secondary school teachers at Maropeng and the Sterkfontein caves, South Africa.

Interpretation, either explicitly or implicitly, aims to stimulate, facilitate and extend people’s understanding of the place or attraction so that empathy towards heritage, conservation, culture and landscape can be developed. However, in tourism research, interpretation in tour guiding has previously not received the attention it deserves. The main aim of this paper is to explore the role of tourist guides in interpretation as perceived by secondary school teachers. In general, respondents perceived tourist guides’ interpretation to be important, and they were satisfied with the way in which guides applied the principles of interpretation throughout their tours. Understanding visitor satisfaction presents information related to how well the attributes of the tourist attraction match the visitors’ preferences, which may help tourist attraction marketers in improving the quality of their products and services in order to meet visitors’ preferences. In addition, marketers should attract a number of visitors that can be managed in order to protect the natural and cultural resources of the attraction. The results of this study will hopefully inform Maropeng á Afrika marketers about secondary school teachers’ satisfaction on tourist guides’ interpretation and how important interpretation is to the respondents. In addition, the results will help the attractions to improve guided school tours and enhance offerings to Maropeng and the Sterkfontein caves in South Africa

Sensory profiling of Egyptian goose (Alopochen aegyptiacus) meat

a b s t r a c t a r t i c l e i n f o No sensory profile information is available for Egyptian goose (Alopochen aegyptiacus) meat. The aim of this study was to conduct descriptive analysis in order to establish the sensory attributes of the breast portion of this species. Meat from guineafowl, Pekin duck, ostrich and broiler chicken were used as reference species. Egyptian goose meat had a very intense game aroma, game flavour and metallic aftertaste, mainly attributable to the muscle's high percentage of polyunsaturated fatty acids and Fe. Egyptian goose meat was also low in tenderness and high residue; this may be due to the high level of physical exercise endured by the breast muscle. Egyptian goose meat proved to be similar to ostrich meat regarding appearance (dark, red colour) and low tenderness, but differed from guineafowl and broiler chicken, the latter two meat types illustrated a higher degree of juiciness and tenderness. These results of Egyptian goose meat can now be used for further sensory studies as it is important to also establish the influence of extrinsic factors such as season and gender on the meat quality of this waterfowl species

Extracellular Vesicles Secreted in Response to Cytokine Exposure Increase Mitochondrial Oxygen Consumption in Recipient Cells

Extracellular vesicles (EVs) are small, membrane-bound nanoparticles released from most, if not all cells, and can carry functionally active cargo (proteins, nucleic acids) which can be taken up by neighboring cells and mediate physiologically relevant effects. In this capacity, EVs are being regarded as novel cell-to-cell communicators, which may play important roles in the progression of neurodegenerative diseases, like Alzheimer’s disease (AD). Aside from the canonical physical hallmarks of this disease [amyloid β (Aβ) plaques, neurofibrillary tangles, and widespread cell death], AD is characterized by chronic neuroinflammation and mitochondrial dysfunction. In the current study, we sought to better understand the role of tumor necrosis factor-alpha (TNF-α), known to be involved in inflammation, in mediating alterations in mitochondrial function and EV secretion. Using an immortalized hippocampal cell line, we observed significant reductions in several parameters of mitochondrial oxygen consumption after a 24-h exposure period to TNF-α. In addition, after TNF-α exposure we also observed significant upregulation of two microRNAs (miRNAs; miR-34a and miR-146a) associated with mitochondrial dysfunction in secreted EVs. Despite this, when naïve cells are exposed to EVs isolated from TNF-α treated cells, mitochondrial respiration, proton leak, and reactive oxygen species (ROS) production are all significantly increased. Collectively these data indicate that a potent proinflammatory cytokine, TNF-α, induces significant mitochondrial dysfunction in a neuronal cell type, in part via the secretion of EVs, which significantly alter mitochondrial activity in recipient cells